Comments: The Oregon Department of Energy offers these comments to reflect its perspective as a Program Administrator in WREGIS since the enactment of Oregon’s Renewable Portfolio Standard in 2007.
WREGIS serves a critical role in Oregon’s regulatory and policy landscape. Pursuant to administrative rules adopted by ODOE, WREGIS has been and remains today the only system of renewable energy certificates that can be used to establish compliance with the Oregon RPS. WREGIS also enables Oregon utilities to provide voluntary REC offerings to customers.
With WREGIS’s software vendor contract set to expire in December 2027, action is needed to ensure the WREGIS platform’s continued viability. ODOE appreciates and supports WECC and WREGIS’s prompt attention to this matter. For ODOE, the most important outcome is that the WREGIS platform continues to offer the functions and services necessary for the Oregon RPS at a reasonable cost to Oregon ratepayers. The loss of the WREGIS platform could have potentially devastating cost impacts to renewable energy facilities that are critical to meeting Oregon’s clean energy goals and which already face severe headwinds from federal policy changes. At the same time that the platform is maintained, costs must be carefully evaluated before investing in platform functionalities that are not necessary for regulatory needs.
ODOE understands the WECC Board has determined that separating WREGIS from WECC is helpful to further the continued viability of the WREGIS platform. The proposal to form a stand-alone WREGIS as a non-profit corporation with a hybrid board of directors advised by a stakeholder advisory group could be a reasonable course of action. Again, the ultimate test must be whether the WREGIS platform, under that governance, is able to continue to offer the functions and services necessary for the Oregon RPS at a reasonable cost to Oregon ratepayers.
ODOE appreciates this opportunity to engage and will continue to follow these proceedings with interest.
Submitted:
Last Name: Weskamp
First Name: Rebecca
Organization: Carbon Solutions Group
Comments: We would like additional consideration be given to the proposed separation of WREGIS from WECC. Of particular concern, there is no indication that such a move would support the upcoming software transition—a transition that is central to maintaining confidence in the registration and tracking of renewable energy credits. Until there are clear details on how a stand-alone WREGIS would operate, it is difficult to assess whether separation would strengthen outcomes or, instead, compromise accountability and reliability. We believe it is essential that these details be determined in advance of any decision, and that the WECC Board establish a transparent process for stakeholders to raise issues and provide input, ensuring that the future of WREGIS reflects the needs of all parties who rely on accurate registration and tracking.
Submitted:
Last Name: Jones
First Name: Todd
Organization: Center for Resource Solutions (CRS)
Comments: Please see the PDF attached for CRS's complete set of comments.
Comments: WRA appreciates the opportunity to provide feedback and provides the attached comments addressing the recommended corporate structure and governance for WREGIS and the future of WREGIS software.
Organization: Public Utilities Commission of Nevada
Comments: The Public Utilities Commission of Nevada (“Commission”) and the Regulatory Operations Staff of the Commission (“Staff”) appreciate WECC’s efforts in preparing a RFP for a new vendor to support WREGIS, as well as the proposal for WREGIS to be an independent entity to better serve stakeholders’ interests. We have read the “Request for Proposal: WREGIS Software Platform Development” put forward by WECC and agree that a minimum viable product is an appropriate starting point to ensure a smooth transition to a new platform. We have also reviewed the materials published on WECC’s website related to making WREGIS a stand-alone entity. The Commission and Staff respectfully submit the following comments in response to the proposals:
1. In recent years, Staff has had very little visibility regarding companies’ compliance with the Nevada Renewable Portfolio Standard (“RPS”). To get the insight necessary for Staff and the Commission to vet utilities’ claimed compliance with the Nevada RPS, Staff is required to perform additional work. The Commission and Staff request that WREGIS, as a stand-alone entity or in its current structure, work with regulators to develop a more efficient product in the future.
2. At the onset of the Nevada RPS, the program had fewer than 100 residential and small business producers. Those producers sold their Portfolio Energy Credits (“PECs”) directly to their load serving entity, which was required to purchase the PECs. There are currently thousands of residential and small business renewable energy producers in Nevada. The reporting requirements and the necessity to aggregate production to sell the attributes mean that, as far as Staff and the Commission are aware, not a single residential or small business credit has been sold since 2013. Staff and the Commission request that WREGIS expand credit aggregating and trading for smaller producers throughout its footprint.
3. Regarding the structure of an independent WREGIS, the Commission and Staff urge WREGIS and/or WECC to maintain an equitable balance of state representation with at least one representative voted on by the members and one representative seat provided to the state with the largest volume of transactions. However, the Commission and Staff would be interested in exploring alternative structures to balance the interests of western states’ interests.
Thank you,
Cameron Dyer, Deputy General Counsel
Submitted:
Last Name: Allen
First Name: Clarissa
Organization: Bonneville Power Administration
Comments: Hello - Please see attached PDF document for comments from Bonneville Power Administration.
Comments: We believe additional consideration should be given to the proposed WREGIS/WECC split. Stakeholders were not properly consulted ahead of the WECC Board’s June decision to explore separation, and no evidence has been provided that such a move would improve oversight or accountability. There is also no evidence that separating from WECC would enhance the upcoming software transition, which is a major stakeholder concern, and it could instead mean losing the guidance, stability, and institutional support that WECC has historically provided during this critical time. Without clear details on how a stand-alone WREGIS would function, it is impossible to assess whether separation would strengthen outcomes or instead reduce accountability. These details are critical and should be determined before any decision is made. The WECC Board should also establish a clear and effective process for stakeholders to raise issues and concerns related to WREGIS, ensuring that feedback leads to meaningful, actionable outcomes that reflect all stakeholder input.
Submitted:
Last Name: Scharff
First Name: Austin
Organization: Washington State Department of Commerce